The North Dakota Office of Attorney General serves as the state’s primary gambling regulatory authority, exercising comprehensive oversight over charitable gaming operations and tribal-state gaming compacts through its dedicated Gaming Division. Established under constitutional and statutory authority, this regulatory body administers licensing, conducts audits and investigations, enforces compliance, and ensures the integrity of games of chance conducted by eligible nonprofit organizations across the state.
According to Gambling databases research team analysis, the Gaming Division regulates over 300 licensed charitable organizations conducting gaming activities at nearly 1,000 permitted locations statewide, generating substantial revenue for educational, charitable, patriotic, fraternal, religious, and public-spirited purposes throughout North Dakota communities. The division’s regulatory scope encompasses bingo, pull-tabs, raffles, electronic gaming devices, sports pools, paddlewheels, twenty-one, poker, calcuttas, and other authorized games of chance, while also enforcing five tribal-state Indian casino gaming compacts.
This comprehensive analytical profile examines the organizational structure, governance framework, licensing operations, enforcement mechanisms, market oversight functions, and stakeholder engagement procedures of the North Dakota Office of Attorney General’s Gaming Division. The article provides practical guidance for industry stakeholders, legal professionals, operators, and researchers seeking detailed understanding of this jurisdictional regulatory framework.
📊 Executive Dashboard
| Metric Category | Indicator | Details |
|---|---|---|
| Organizational Foundation | Official Name | North Dakota Office of Attorney General – Gaming Division |
| Establishment | Statutory authority under NDCC Chapter 53-06.1; Gaming Division operational structure defined in N.D. Admin. Code § 10-01-01-01 | |
| Legal Basis | North Dakota Constitution Article XI, Section 25; NDCC Chapter 53-06.1 (Games of Chance); N.D. Admin. Code Article 99-01.3 | |
| Parent Ministry | Office of Attorney General (one of 13 divisions within the office) | |
| Jurisdictional Scope | Geographic Coverage | Statewide jurisdiction across all 53 North Dakota counties |
| Gambling Types Regulated | Charitable gaming (bingo, pull-tabs, raffles, electronic devices, sports pools, paddlewheels, twenty-one, poker, calcuttas); Tribal casino gaming compact enforcement | |
| Number of Licensees | 300+ licensed charitable gaming organizations | |
| Gaming Sites | Nearly 1,000 permitted gaming locations statewide | |
| Leadership & Structure | Attorney General | Drew H. Wrigley (elected constitutional officer) |
| Gaming Division Director | Aaron Hummel (appointed 2025) | |
| Organizational Structure | Division Director, Audit Section, Tax Section, Investigation Section, Licensing Section, Training/Communications Specialist, Administrative Assistant | |
| Staff Size | 20 FTE positions (1 Division Director, 13 auditors, 2 audit technicians, 2 investigators, 1 training/communications specialist, 1 administrative assistant) | |
| Contact Information | Physical Address | 600 East Boulevard Avenue, Dept. 125, Bismarck, ND 58505-0040 |
| General Phone | (701) 328-2210 | |
| Gaming Division Phone | (701) 328-4848 / 1-800-326-9240 | |
| General Email | [email protected] | |
| Official Website | https://attorneygeneral.nd.gov/licensing-and-gaming/gaming/ | |
| Online Portal | Web-based online licensing system (launched April 2026) | |
| Office Hours | Standard state business hours (specific hours not publicly disclosed) | |
| Public Registry | Online licensing portal provides access to current and past license applications | |
| Regulatory Powers | Licensing Authority | Issues charitable gaming licenses, manufacturer/distributor licenses, site authorizations; administers local permit oversight |
| Enforcement Powers | Conducts audits and investigations; issues administrative complaints; imposes fines, penalties, license suspensions and revocations; refers criminal violations | |
| Inspection Authority | May inspect all gaming sites, manufacturing/distribution premises; conducts random inspections at tribal casinos | |
| Rule-Making | Administrative rules adopted through ND State Gaming Commission process (N.D. Admin. Code Article 99-01.3) | |
| Civil Action | May bring civil action for collection of fees, taxes, and to force compliance (NDCC § 53-06.1-15.2) | |
| Operational Metrics | Annual Budget | Funded through gaming tax revenue and state appropriations (estimated $53 million in gaming tax revenue for 2023-25 biennium) |
| Funding Sources | Gaming taxes (1% of adjusted gross proceeds from e-tabs; other game types taxed per statute), licensing fees, state General Fund appropriations | |
| Licensing Revenue | $175 per city/county for charitable organizations; $1,000-$10,000 for manufacturers/distributors depending on equipment type | |
| Enforcement Actions | 197+ complaints investigated (FY 2023-25 data); multiple administrative complaints filed; license revocations and penalties imposed | |
| Licensing Portfolio | License Types Issued | Charitable gaming organization licenses; manufacturer licenses; distributor licenses; site authorizations; local permits (oversight) |
| Active Licenses | 300+ charitable gaming organization licenses | |
| Application Volume | Annual licensing cycle with 90-day filing period; all applications now processed through online system (launched April 2026) | |
| Approval Process | Background checks, financial review, documentation verification, site authorization approval | |
| Online Transition | Paper applications no longer accepted (effective February 2026); mandatory online filing for licenses and tax returns | |
| Compliance Framework | Inspection Frequency | 75+ comprehensive and in-office audits completed (FY 2023-25); random inspections at tribal casinos; field audits of gaming organizations |
| Audit Requirements | Independent audit of closed games/daily activity required (N.D. Admin. Code § 99-01.3-03-10(7)); quarterly tax return filing | |
| Reporting Obligations | Quarterly gaming tax returns; incident reports; annual license renewal; financial records and prize redemption documentation | |
| Technology Systems | Online licensing portal (launched April 2026); mandatory online tax filing (effective Q3 2026); QR code option for laws/rules access | |
| International Relations | Tribal-State Compacts | Enforces five tribal-state Indian casino gaming compacts; conducts random inspections at state’s five Indian casinos |
| Interstate Cooperation | Coordination with other state gaming regulators; information sharing on compliance matters | |
| Federal Interface | Compliance with Indian Gaming Regulatory Act (IGRA); limited waiver of sovereign immunity for compact enforcement | |
| Professional Associations | Participation in gaming regulator forums and training programs | |
| Public Accessibility | Website Functionality | Comprehensive resource library with forms, laws, rules, newsletters, guidance documents, FAQs |
| Public Registry Access | Online portal provides license application access; gaming organization information available through division | |
| Complaint Mechanisms | Gaming complaint form available online; investigation section handles consumer complaints and incident reports | |
| Transparency Initiatives | Quarterly newsletters (Gaming Insights); preliminary fiscal year reports published; public hearing notices for rule changes | |
| Training & Education | Training programs for organizations, boards of directors, gaming personnel; expanded training presence planned |
🏛 Section 1: Organizational Structure and Governance Framework
Establishment, Legal Foundation, and Institutional Evolution
The North Dakota Office of Attorney General’s Gaming Division operates under constitutional and statutory authority established through multiple legislative enactments. Article XI, Section 25 of the North Dakota Constitution provides the foundational framework, prohibiting gambling unless expressly authorized by the Legislature or Constitution, while permitting bona fide nonprofit organizations to conduct games of chance when net proceeds benefit educational, charitable, patriotic, fraternal, religious, or public-spirited purposes.
Chapter 53-06.1 of the North Dakota Century Code (Games of Chance) constitutes the primary statutory authority governing charitable gaming operations, with substantive amendments effective August 1, 2025. The Attorney General is statutorily designated as the licensing authority responsible for determining organizational eligibility and issuing gaming licenses to qualified entities. Administrative rules implementing these statutes are codified in Article 99-01.3 of the North Dakota Administrative Code, with comprehensive revisions effective July 1, 2026.
The Gaming Division’s institutional evolution reflects North Dakota’s distinctive approach to gambling regulation, which prohibits commercial gambling while permitting charitable gaming under strict constitutional and statutory constraints.
The organizational structure of the Office of Attorney General is defined in N.D. Admin. Code § 10-01-01-01, which establishes the Gaming Division as one of 13 divisions within the office. The Gaming Division is specifically responsible for regulating, enforcing, and administering charitable gaming activity in North Dakota, performing office and field audits and investigations of gaming organizations, distributors, and manufacturers.
Historical development of the Gaming Division’s authority includes the 1987 legislation (S.L. 1987, Ch. 627) that expanded the Attorney General’s responsibilities to include compliance enforcement with tribal-state Indian casino gaming compacts. This legislative action aligned state regulatory authority with the federal Indian Gaming Regulatory Act (IGRA) framework, establishing the Attorney General’s role in monitoring tribal gaming operations through compact enforcement mechanisms.
The division’s mission statement emphasizes regulation and licensing that adapts to change while maintaining high integrity standards, ensuring responsible gaming practices across North Dakota’s charitable gaming sector. Strategic objectives include increasing training presence for organizations and gaming personnel, expanding educational opportunities for boards of directors, and implementing streamlined licensing processes through technological modernization.
Major regulatory reforms include the 2026 transition to a comprehensive online licensing system, eliminating paper applications and payments effective immediately. This modernization initiative, launched in April 2026, represents a significant institutional evolution designed to provide faster, more efficient licensing experiences while maintaining rigorous compliance standards.
Legislative context includes Senate Bill 2288 (2025), which authorized veterans’ organizations to use up to twenty percent of net proceeds per quarter for food and beverage costs incurred operating their clubs, demonstrating ongoing statutory refinement of charitable gaming provisions. House Bill 2334 mandated a study related to ownership of alcoholic beverage establishments before the Interim Judiciary Committee, illustrating continued legislative engagement with gaming regulatory issues.
Organizational Structure, Leadership, and Governance Model
The North Dakota Office of Attorney General is led by Attorney General Drew H. Wrigley, an elected constitutional officer who provides overall direction for the office’s 13 divisions. The Gaming Division operates under the leadership of Division Director Aaron Hummel, who was appointed in 2025 and brings extensive public service experience to the role.
The Gaming Division consists of 20 full-time equivalent positions organized into functional sections: Audit Section (supervised by Laura Gleich with 10 auditors), Tax Section (supervised by Patty Wondra with 4 staff including Tax Section Supervisor, 2 staff, and 1 specialist), Investigation Section (supervised by Rob Sanderson with 3 investigators), Licensing Section (2 staff), Training/Communications Specialist (Arin Casavant), and Administrative Assistant (Susan Brockel).
The Gaming Division’s staffing structure reflects comprehensive regulatory capacity, with 13 auditors conducting field and office audits, 2 investigators handling compliance violations, and dedicated licensing and training personnel supporting organizational compliance.
Internal departmental structure includes distinct functional areas: the Audit Section performs comprehensive and in-office audits of gaming organizations, verifying financial accuracy and compliance with statutory requirements; the Tax Section reviews gaming tax returns and ensures proper revenue collection; the Investigation Section conducts criminal history background checks, investigates complaints, and enforces compliance with gaming laws and tribal compacts.
Staffing levels and professional expertise requirements reflect the division’s comprehensive regulatory mandate. Auditors possess accounting and compliance expertise to verify gaming fund receipt, control, and disbursement accuracy; investigators conduct background checks and criminal investigations; licensing personnel manage application processing and organizational eligibility determinations.
Organizational chart and reporting hierarchies place the Gaming Division within the Office of Attorney General’s broader structure, with the Division Director reporting to the Attorney General and Chief Deputy Attorney General. Section supervisors (Laura Gleich for Audit, Patty Wondra for Tax, Rob Sanderson for Investigation) manage their respective functional areas and report to the Division Director.
Advisory committees and stakeholder consultation mechanisms include the ND State Gaming Commission, which conducts public hearings on proposed administrative rules. The division maintains regular communication with charitable gaming organizations through quarterly newsletters (Gaming Insights), training programs, and direct engagement with organization leadership and gaming personnel.
Independence safeguards and conflict-of-interest policies are embedded in administrative rules, particularly regarding independent audit requirements. N.D. Admin. Code § 99-01.3-03-10(7) mandates that closed games or daily activities be audited within a reasonable time by a person independent of the activity, with specific prohibitions on auditors who conducted the game, had sole access to games or receipts, or have familial relationships with game operators.
Decision-making processes and voting procedures for administrative rule changes follow the ND State Gaming Commission’s public hearing process, with opportunities for oral and written comments during designated comment periods. The February 18, 2026 public hearing on proposed rules for Article 99-01.3 demonstrates this participatory regulatory approach, with comments accepted until March 7, 2026.
Accountability mechanisms and oversight bodies include legislative oversight through the North Dakota Legislative Assembly’s budget approval process, with the Office of Attorney General’s appropriations subject to biennial legislative review. The division’s activities are documented in preliminary fiscal year reports published for public review, providing transparency on gaming revenues, expenses, and charitable distributions.
Budget approval and financial oversight structures operate through the state’s executive budget process, with the Office of Management and Budget coordinating agency budget requests. The Attorney General’s office receives ongoing General Fund appropriations (approximately $44.7 million for ongoing operations) supplemented by special fund revenues including gaming taxes and licensing fees.
| Aspect | Details | Notes |
|---|---|---|
| Official Name | North Dakota Office of Attorney General – Gaming Division | One of 13 divisions within the Office of Attorney General |
| Common Abbreviation | ND Gaming Division | Used in official publications and communications |
| Establishment Date | Statutory authority under NDCC Chapter 53-06.1; organizational structure defined in N.D. Admin. Code § 10-01-01-01 | Gaming Division operational structure codified in administrative rules |
| Legal Basis | ND Constitution Article XI, Section 25; NDCC Chapter 53-06.1; N.D. Admin. Code Article 99-01.3 | Primary statutes and administrative rules governing charitable gaming |
| Organizational Type | State regulatory agency (division within Office of Attorney General) | Exercises statutory regulatory authority over charitable gaming |
| Parent Ministry | Office of Attorney General | One of 13 divisions; Attorney General Drew H. Wrigley provides overall leadership |
| Current Head | Division Director: Aaron Hummel (appointed 2025) | Reports to Attorney General Drew H. Wrigley |
| Board/Commission | ND State Gaming Commission (administrative rule-making) | Conducts public hearings on proposed rules |
| Staff Size | 20 FTE positions | 1 Division Director, 13 auditors, 2 audit technicians, 2 investigators, 1 training/communications specialist, 1 administrative assistant |
| Annual Budget | Funded through gaming tax revenue and state appropriations | Estimated $53 million in gaming tax revenue for 2023-25 biennium |
| Headquarters Location | Bismarck, North Dakota | 600 East Boulevard Avenue, Dept. 125, Bismarck, ND 58505-0040 |
| Website | https://attorneygeneral.nd.gov/licensing-and-gaming/gaming/ | English language; comprehensive resource library |
Regulatory Powers, Enforcement Authority, and Jurisdictional Scope
The Gaming Division’s statutory regulatory powers derive from NDCC Chapter 53-06.1, which grants the Attorney General comprehensive authority to administer, regulate, and enforce charitable gaming laws. The Attorney General may inspect all sites where gaming is conducted or where gaming equipment is manufactured or distributed, requiring licensed organizations to maintain accurate records and comply with statutory requirements.
Licensing and approval authority scope encompasses charitable gaming organization licenses, manufacturer licenses, distributor licenses, and site authorizations. The Attorney General determines organizational eligibility based on statutory criteria including nonprofit status, primary purpose alignment with constitutional requirements, and compliance history.
State law prohibits even licensed organizations from conducting online gaming or hosting raffles online, and credit cards cannot be accepted as wagers for gambling including payment for raffle tickets.
Investigation and inspection powers include office and field audits of gaming organizations, distributors, and manufacturers; criminal history background checks of applicants, officers, and stockholders; and random inspections at the state’s five Indian casinos to ensure game integrity and compliance with wager limits and prize payout ratios. The division completed over 75 comprehensive and in-office audits and investigated over 197 complaints during the 2023-25 biennium.
Enforcement mechanisms include administrative complaints, fines, penalties, license suspensions, and revocations. The Attorney General may bring civil action for collection of fees and taxes and to force compliance under NDCC § 53-06.1-15.2. Recent enforcement actions include the March 2026 revocation of Beulah CVB’s gaming license, requiring repayment of $398,287 in improperly expended net proceeds and imposition of a $50,000 penalty.
Ability to impose administrative sanctions and criminal referrals extends to violations of gaming laws and regulations, with the Investigation Section coordinating with local law enforcement on criminal matters. The division’s investigators, including Special Agent Rob Sanderson and Investigator Jacob Marschner, handle compliance violations and criminal referrals.
Regulatory guidance and rule-making authority operates through the ND State Gaming Commission, which conducts public hearings on proposed administrative rules. Article 99-01.3 of the North Dakota Administrative Code contains comprehensive rules governing games of chance, with revisions effective July 1, 2026.
Geographic jurisdiction boundaries encompass all 53 North Dakota counties, with licensing fees assessed at $175 per city or county where gaming sites are authorized. The division maintains statewide oversight of charitable gaming activities, including those conducted under local permits issued by city or county auditors.
Sectors regulated include charitable gaming (bingo, pull-tabs, raffles, electronic quick shot bingo, electronic pull-tab devices, sports pools, paddlewheels, twenty-one, poker, calcuttas, prize boards, club specials) and tribal casino gaming through compact enforcement. The division does not regulate the North Dakota Lottery, which operates as a separate division within the Office of Attorney General.
Exemptions and exclusions from regulatory authority include commercial casino gambling (prohibited under state constitution), online gaming (expressly prohibited by statute), and certain limited gaming activities conducted under local permits without state licensing requirements. Tribal gaming operations are regulated primarily by tribal gaming commissions under IGRA, with the Attorney General enforcing compact provisions.
Coordination with other governmental agencies and law enforcement includes assistance to local law enforcement officials regarding gaming laws and rules, recordkeeping requirements, and tax return preparation. The division coordinates with city and county auditors who issue local permits, requiring them to provide copies of issued permits for statewide compliance review and recordkeeping.
Cross-border enforcement cooperation and mutual assistance agreements extend to tribal-state compact enforcement, with limited waivers of sovereign immunity for compact dispute resolution in United States District Court for the District of North Dakota. The division also coordinates with out-of-state law enforcement on gaming-related criminal investigations, as demonstrated by the identification of out-of-state suspects in gaming theft incidents.
Funding Model, Budget, and Financial Sustainability
The Gaming Division’s annual budget is funded through a combination of gaming tax revenue, licensing fees, and state General Fund appropriations. During the 2023-25 biennium, approximately $53 million in gaming tax revenue was generated, funding regulation and oversight of the industry, gambling disorder programs, with the remainder deposited into the State’s General Fund.
Revenue sources include licensing fees ($175 per city or county for charitable organizations; $1,000-$10,000 for manufacturers/distributors depending on equipment type), gaming taxes (1% of adjusted gross proceeds from e-tabs and other game types per statute), and state appropriations. The Attorney General deposits $25 of each $175 charitable organization licensing fee into the charitable gaming technology fund under NDCC § 53-06.1-12.4.
Gaming tax revenue of approximately $53 million for the 2023-25 biennium funds regulatory operations, gambling disorder programs, and contributes to the State’s General Fund, demonstrating the division’s financial self-sufficiency.
Government appropriations and public funding components include ongoing General Fund appropriations to the Office of Attorney General (approximately $44.7 million for ongoing operations across all divisions), with the Gaming Division’s specific allocation embedded within the broader office budget. The 2011-13 biennium appropriation included $261,128 of revenue from tribes to pay for state regulation of tribal gaming.
Financial independence and self-sufficiency level is substantial, with gaming tax revenue and licensing fees covering a significant portion of regulatory costs. The division’s operations are funded primarily by the industry it regulates, minimizing reliance on general taxpayer funds.
Fee structures and calculation methodologies are established by statute, with charitable organizations paying $175 per city or county where gaming sites are authorized. Manufacturer license fees range from $1,000 (electronic raffle systems) to $10,000 (electronic pull tab systems or devices), with intermediate tiers at $1,500 (paper pull tab dispensing devices) and $5,500 (pull tabs, bingo cards, electronic quick shot bingo systems).
Budget approval processes and legislative oversight operate through the biennial appropriations process, with the Office of Attorney General’s budget submitted to the Legislative Assembly for review and approval. The 2027-29 base-level budget request includes ongoing General Fund appropriations of approximately $44.7 million for the Attorney General’s office.
Financial reporting and public accountability are demonstrated through preliminary fiscal year reports published by the Gaming Division, detailing gross proceeds, prizes, adjusted gross proceeds, cash profits, gaming taxes, and eligible use contributions. Fiscal Year 2025 preliminary data shows $28.26 million in gaming taxes collected and $95.13 million in eligible use contributions to charitable purposes.
Reserve funds and financial stability mechanisms include the charitable gaming technology fund, which receives $25 from each charitable organization licensing fee for technology infrastructure and system modernization. The transition to online licensing and tax filing systems represents investment of these funds in regulatory modernization.
Historical budget trends and funding challenges reflect the growth of charitable gaming, particularly electronic pull-tab devices, which generated $213 million in adjusted gross proceeds in 2024 compared to zero in 2018. This rapid growth has increased regulatory workload and necessitated technological modernization of licensing and tax filing systems.
| Contact Type | Details |
|---|---|
| Official Name | North Dakota Office of Attorney General – Gaming Division |
| Regulatory Body Abbreviation | ND Gaming Division |
| Physical Address | 600 East Boulevard Avenue, Dept. 125, Bismarck, ND 58505-0040 |
| General Phone | (701) 328-2210 (Office of Attorney General); (701) 328-4848 / 1-800-326-9240 (Gaming Division) |
| General Email | [email protected] |
| Official Website | https://attorneygeneral.nd.gov/licensing-and-gaming/gaming/ |
| Online Portal | Web-based online licensing system (launched April 2026) |
| Media Contact | Suzie Weigel, (701) 328-2210, [email protected] |
| Investigative Section | Special Agent Rob Sanderson (701) 328-5546); Investigator Jacob Marschner (701) 328-2313) |
📝 Section 2: Licensing Operations and Regulatory Functions
Licensing Portfolio, Permit Types, and Authorization Framework
The North Dakota Attorney General’s Gaming Division administers a comprehensive licensing portfolio encompassing charitable gaming organization licenses, manufacturer and distributor licenses, site authorizations, and local permit oversight. State law requires proper authorization before any game of chance may be conducted, with different approvals required depending on the activity type and organizational structure.
Charitable gaming organization licenses are issued to bona fide nonprofit organizations that want to conduct games of chance such as raffles, bingo, pull-tabs, or similar activities. The license authorizes the organization to operate approved games of chance in accordance with North Dakota law and administrative rules, and only at properly authorized locations. Organizations must be registered as nonprofits with the North Dakota Secretary of State for at least two years prior to application.
Eligible organizations include veterans’, charitable, educational, religious, fraternal, civic, and service organizations that devote net proceeds to educational, charitable, patriotic, fraternal, religious, or other public-spirited purposes.
Gaming manufacturer and distributor licenses are required for businesses that manufacture, sell, lease, or distribute gaming equipment or gaming supplies for use in charitable gaming. This includes items such as pull-tab tickets, bingo equipment, electronic pull-tab devices, and related gaming supplies. Licensing ensures all equipment used in North Dakota charitable gaming meets security, testing, and accountability standards.
Manufacturer license fees are based on equipment type: $1,500 for manufacturers of paper pull-tab dispensing devices; $5,500 for manufacturers of pull-tabs, bingo cards, electronic quick shot bingo systems and devices, or bingo card marking devices; $10,000 for manufacturers of electronic pull-tab systems or devices; and $1,000 for manufacturers of electronic raffle systems. Distributor licenses require annual application and payment of a $2,000 license fee.
Local and restricted event permits are issued through the organization’s local city or county auditor’s office, with oversight from the Attorney General’s Gaming Division. These permits are typically used for small or short-term gaming activities that do not require a full state gaming license, but organizations must still follow North Dakota charitable gaming laws and restrictions.
License classification systems distinguish between operator licenses (charitable gaming organizations), supplier licenses (manufacturers and distributors), and individual licenses (key employees, gaming managers, board members). Each license type has specific eligibility criteria, documentation requirements, and ongoing compliance obligations.
License scope limitations and permitted activities under each type are defined by statute and administrative rule. Charitable gaming licenses authorize specific game types (bingo, pull-tabs, raffles, electronic devices, etc.) at approved sites, with site authorizations required for each gaming location.
Concurrent licensing across multiple gambling verticals is permitted for organizations authorized to conduct multiple game types, with each game type and site requiring appropriate authorization. Organizations may operate at multiple sites across multiple cities and counties, paying $175 licensing fee per city or county where gaming sites are located.
The licensing framework prohibits online gaming, with state law expressly forbidding even licensed organizations from conducting online gaming or hosting raffles online. Credit cards cannot be accepted as wagers for gambling, including payment for raffle tickets. These prohibitions reflect constitutional and statutory constraints on gambling authorization in North Dakota.
Application Procedures, Processing Standards, and Approval Metrics
Application submission procedures transitioned to a mandatory online licensing system effective April 2026, with paper applications and payments no longer accepted. All charitable gaming license applications and renewals must be completed through the web-based online licensing portal, with links and instructions posted on the Gaming Division website.
Documentation requirements for charitable gaming organization licenses include: organization personnel information (gaming organization details, gaming manager, top official, governing board members, primary contact, independent auditor, employee list); tax-exempt certificate issued by the IRS; Federal Employer Identification Number (FEIN); date of nonprofit registration with North Dakota Secretary of State (must be at least two years prior); type of eligible organization; charter document (if applicable); articles of incorporation; charitable organization statement of primary purpose; corporate certificate; organizational by-laws; board of director meeting minutes for the previous two years.
Background checks for employees must be completed through the North Dakota Bureau of Criminal Investigation within 21 days of employment and every 6 years thereafter, with record check documentation uploaded during application.
Background investigation procedures and vetting standards require criminal history background checks of applicants, officers, and stockholders conducted by the Gaming Division’s Investigation Section. Employee record checks must be completed within 21 days of employment and every 6 years after, with documentation uploaded to the online licensing portal.
Financial suitability assessments and capital verification include review of organizational financial records, bank account information, and gaming fund management practices. Organizations must demonstrate proper internal controls, including independent audit procedures and segregated gaming accounts.
Technical review processes for gaming systems and equipment apply primarily to manufacturers and distributors, who must demonstrate equipment meets security, testing, and accountability standards. Electronic pull-tab systems and devices require specific licensing and compliance with technical specifications.
Application processing timelines vary by license type, with the online system processing applications in the order received. Manufacturers and distributors access the system first during their designated application window, followed by charitable gaming organizations with a 90-day filing period. The application window for Fiscal Year 2027 opens April 1, 2026, with submissions due by June 1, 2026, and the new fiscal year beginning July 1, 2026.
Review stages include preliminary assessment (documentation completeness verification), full investigation (background checks, financial review, site authorization verification), and board approval (licensing section recommendation). Once approved, licenses and site authorizations are available immediately within the online system and may be printed at any time.
Approval and denial statistics are not publicly disclosed in detail, but the division processes hundreds of license applications annually for 300+ licensed organizations. The online licensing system enables tracking of current and past license applications for organizational reference.
Application fee structures require $175 per city or county where gaming sites are authorized for charitable organizations. Manufacturer fees range from $1,000 to $10,000 depending on equipment type, with distributor licenses requiring $2,000 annual fees. Fees are paid through the online portal, with cash and check payments no longer accepted.
Conditional approvals and provisional licenses may be issued under specific circumstances, with the Attorney General authorized to issue conditional licenses to eligible organizations whose regularly issued licenses have expired, been suspended, revoked, or relinquished. Conditional licenses are subject to compliance requirements and may be revoked for violations.
Appeal procedures for denied applications follow administrative hearing processes under chapter 28-32 of the North Dakota Century Code, with licensees entitled to due process protections. Organizations may request hearings to contest licensing decisions or enforcement actions.
License issuance procedures and activation requirements include online portal access, printing of licenses and site authorizations, and compliance with ongoing reporting obligations. Organizations may update organization details, employees, sites, and authorized game types throughout the year through the online system.
| License Type | Fee Structure | Application Requirements | Processing Timeline |
|---|---|---|---|
| Charitable Gaming Organization | $175 per city/county | Nonprofit registration (2+ years), IRS tax-exempt certificate, FEIN, articles of incorporation, by-laws, board minutes (2 years), background checks | 90-day filing period; processed in order received |
| Manufacturer (Paper Pull-Tab Devices) | $1,500 | Business registration, equipment specifications, compliance documentation | Designated application window; processed in order received |
| Manufacturer (Pull-Tabs, Bingo Cards, Electronic Quick Shot) | $5,500 | Business registration, equipment testing documentation, security standards compliance | Designated application window; processed in order received |
| Manufacturer (Electronic Pull-Tab Systems) | $10,000 | Business registration, comprehensive technical specifications, security audits | Designated application window; processed in order received |
| Manufacturer (Electronic Raffle Systems) | $1,000 | Business registration, system specifications, compliance documentation | Designated application window; processed in order received |
| Distributor | $2,000 annually | Business registration, equipment sourcing documentation, compliance agreements | Designated application window; processed in order received |
| Local Permit (Oversight) | Varies by jurisdiction | Local application, organization eligibility documentation, site authorization | Issued by city/county auditor; Gaming Division receives copies |
Compliance Monitoring, Inspection Programs, and Enforcement Operations
Ongoing compliance monitoring systems include quarterly tax return filing requirements, independent audit verification, and incident reporting mechanisms. Beginning with the quarter ending September 30, 2026, all gaming tax returns must be filed online, with paper returns no longer accepted. Organizations must submit incident reports directly through the online portal.
Scheduled inspection frequency by license type and gambling sector includes over 75 comprehensive and in-office audits completed during the 2023-25 biennium. The Audit Section, supervised by Laura Gleich with 10 auditors, conducts field audits of gaming organizations to verify financial accuracy and compliance with statutory requirements.
Independent audit requirements mandate that closed games or daily activities be audited within a reasonable time by a person independent of the activity, with specific prohibitions on auditors who conducted the game or had sole access to games or receipts.
Unannounced inspection authority and practices extend to all gaming sites, with the Attorney General statutorily authorized to inspect all sites where gaming is conducted. Random inspections are conducted at the state’s five Indian casinos to ensure game integrity and compliance with wager limits and prize payout ratios.
Gaming equipment testing and certification requirements apply to manufacturers and distributors, who must ensure equipment meets security, testing, and accountability standards. Electronic pull-tab systems and devices require specific technical specifications and compliance verification.
Financial audit requirements and accounting standards include independent audit of closed games or daily activity pursuant to N.D. Admin. Code § 99-01.3-03-10(7). The independent audit person must verify number and value of unsold chances, gross proceeds, number and value of prizes, adjusted gross proceeds, and cash profit.
Anti-money laundering oversight and suspicious activity monitoring are embedded in compliance requirements, with organizations required to maintain accurate records of gaming fund receipt, control, and disbursement. The Investigation Section handles suspicious activity reports and coordinates with law enforcement on criminal matters.
Responsible gambling compliance verification includes enforcement of prize limits, game integrity standards, and player protection measures. The division investigates consumer complaints involving gaming devices and ensures prompt resolution of player disputes.
Player protection measure enforcement includes requirements for immediate action when gaming device incidents occur, with organizations responsible for stopping play, contacting distributors, and following reporting requirements. Continuing to play on a machine after an incident risks additional complaints and complicates incident investigation.
Advertising and marketing compliance reviews ensure organizations comply with statutory restrictions on gaming promotion, particularly regarding online advertising prohibitions. Organizations must accurately represent gaming activities and net proceeds disbursements.
Technology and cybersecurity audits apply to electronic gaming systems, with manufacturers and distributors required to maintain system security and integrity. The online licensing portal incorporates cybersecurity measures to protect organizational and personal information.
Complaint investigation procedures and resolution timelines involve the Investigation Section, which investigated over 197 complaints during the 2023-25 biennium. Consumer complaints involving electronic pull-tab devices are handled with emphasis on prompt resolution at the site level.
Whistleblower programs and confidential reporting mechanisms include the BCI Tip Line (1-800-472-2185 within ND) for reporting suspicious activity or violations. The Gaming Division accepts incident reports through the online portal and investigates complaints filed by players, organizations, or the public.
Compliance assistance and educational programs for licensees include quarterly newsletters (Gaming Insights), training programs for organizations and gaming personnel, and expanded training opportunities for boards of directors. The Training/Communications Specialist (Arin Casavant) develops educational materials and manages statewide training outreach.
Enforcement Actions, Penalty Framework, and Disciplinary Procedures
Enforcement authority scope and legal basis derive from NDCC Chapter 53-06.1 and N.D. Admin. Code Article 99-01.3, with the Attorney General authorized to issue administrative complaints, impose penalties, and revoke licenses for violations. The Attorney General may bring civil action for collection of fees and taxes and to force compliance under NDCC § 53-06.1-15.2.
Violation categories and offense classifications include false reporting, false documentation, conflict of interest, unlawful transactions, improper transfers of net proceeds, and inaccurate reporting on official documents. Recent enforcement actions against Beulah CVB included false reporting of $277,747 in net proceeds disbursements, false documentation of donations, conflict of interest by board member, and unlawful use of over $100,000 in net proceeds for ineligible purposes.
License revocation, repayment of improperly expended funds, and substantial penalties may be imposed for serious violations, as demonstrated by the March 2026 enforcement action against Beulah CVB requiring $398,287 repayment and $50,000 penalty.
Penalty types include monetary fines, license suspensions, revocations, prohibitions on participation in gaming activities, and requirements to repay improperly expended net proceeds. The July 2023 enforcement action against Western Distributing, Plains Gaming Distributing, and Midwest Gaming Distributing alleged millions of dollars in charitable gaming proceeds improperly diverted through unlawful rent payments and interference with lessor relationships.
Fine structures and maximum penalty limits are determined case-by-case based on violation severity, with recent penalties including $50,000 to Beulah CVB, $2,500 to NumberWorks LLC, and $2,500 to individual Les Leonard. Statutory authority permits civil action for fee and tax collection with additional penalties.
Administrative sanctions versus criminal referrals distinguish between regulatory violations handled through administrative complaints and criminal violations referred to law enforcement. The Investigation Section coordinates with local law enforcement on criminal gaming violations and thefts.
Progressive discipline policies and escalation procedures include administrative complaints, license suspensions, revocations, and prohibitions on future participation. Organizations and individuals have opportunity to respond and request hearings before final enforcement actions.
Settlement agreements and consent orders may be negotiated in appropriate cases, with organizations able to contest enforcement actions through administrative hearing processes. The Attorney General emphasizes fair enforcement intended to uphold integrity of charitable gaming.
Emergency suspension authority for immediate threats permits the Attorney General to suspend or revoke licenses on the Attorney General’s own motion based on reasonable grounds or on written complaint, in accordance with chapter 28-32. Immediate threats to game integrity or public safety may warrant emergency action.
License revocation procedures and due process protections include notice of administrative complaints, opportunity to respond, and right to request hearings. The March 2026 Beulah CVB enforcement action provided opportunity for the organization and individuals involved to respond and request hearings.
Public disclosure of enforcement actions is made through press releases and website postings, with media contacts providing information on enforcement actions. Enforcement actions are intended to uphold integrity of charitable gaming and ensure compliance across North Dakota.
Historical enforcement statistics include over 197 complaints investigated during the 2023-25 biennium, with multiple administrative complaints filed and license revocations imposed. The July 2023 enforcement action against three distributors alleged millions of dollars in improperly diverted charitable gaming proceeds.
Notable enforcement cases and precedent-setting actions include the March 2026 Beulah CVB revocation, which established enforcement parameters for false reporting, false documentation, conflict of interest, and unlawful net proceeds disbursements. The July 2023 distributor enforcement action addressed unlawful rent payments and interference with lessor relationships.
Operator rights and appeal mechanisms include administrative hearing processes under chapter 28-32, with licensees entitled to due process protections. Organizations may contest enforcement actions through hearings and appeals.
Reinstatement procedures after disciplinary action require compliance with all penalty requirements, repayment of improperly expended funds, and demonstration of organizational reforms to prevent future violations. Conditional licenses may be issued to organizations whose licenses were revoked, subject to strict compliance requirements.
| Enforcement Action Type | Example Case | Penalty Imposed | Legal Basis |
|---|---|---|---|
| License Revocation | Beulah CVB (March 2026) | License revoked; $398,287 repayment; $50,000 penalty | False reporting, false documentation, conflict of interest, unlawful transactions |
| Administrative Complaint | Western/Plains/Midwest Distributing (July 2023) | Administrative complaint filed; millions in improperly diverted proceeds alleged | Unlawful rent payments, interference with lessor relationships, diversion of net proceeds |
| Monetary Fine | NumberWorks LLC (March 2026) | $2,500 fine | Involvement in unlawful transactions leading to violations |
| Individual Penalty | Les Leonard (March 2026) | $2,500 fine | Individual involvement in violations |
| Site Authorization Suspension | Uncle Maddio’s Pizza (March 2026) | 90-day suspension | Site involved in unlawful transactions |
| Participation Prohibition | Beulah CVB individuals (March 2026) | Prohibition on gaming participation | Individual involvement in violations |
📈 Section 3: Market Oversight and Stakeholder Engagement
Market Statistics, Industry Metrics, and Economic Impact
Total number of active licenses by category includes 300+ licensed charitable gaming organizations authorized to conduct games of chance across North Dakota. Gaming activities occur at nearly 1,000 permitted locations statewide, with organizations conducting multiple game types at authorized sites.
Number of licensed operators and gambling establishments encompasses charitable organizations, veterans’ groups, fraternal organizations, religious organizations, educational institutions, and civic groups. Each organization may operate at multiple sites across multiple cities and counties, with site authorizations required for each location.
Number of licensed suppliers, manufacturers, and service providers includes manufacturers of gaming equipment (paper pull-tab dispensing devices, pull-tabs, bingo cards, electronic quick shot bingo systems, electronic pull-tab systems, electronic raffle systems) and distributors of gaming equipment and supplies. Manufacturer and distributor licenses ensure equipment meets security, testing, and accountability standards.
Individual licensee counts include gaming managers, top officials, governing board members, independent auditors, and employees of charitable gaming organizations. All employees must complete background checks through the North Dakota Bureau of Criminal Investigation within 21 days of employment and every 6 years thereafter.
Fiscal Year 2025 preliminary data shows $2.52 billion in gross proceeds, $285.27 million in adjusted gross proceeds, $102.65 million in net proceeds, and $95.13 million in eligible use contributions to charitable purposes.
Annual licensing revenue generated by the regulator includes $175 per city or county for charitable organizations, with manufacturer fees ranging from $1,000 to $10,000 and distributor fees at $2,000 annually. Gaming tax revenue of approximately $53 million was generated during the 2023-25 biennium.
Total market revenue under regulatory oversight reached $2.52 billion in gross proceeds for Fiscal Year 2025, with $285.27 million in adjusted gross proceeds and $102.65 million in net proceeds. Electronic pull-tab devices generated $2.31 billion in gross proceeds, representing the dominant game type by revenue.
Tax and fee collection totals include $28.26 million in gaming taxes for Fiscal Year 2025, with additional federal excise tax of $396,599.92. Licensing fees contribute additional revenue to fund regulatory operations and the charitable gaming technology fund.
Economic impact of regulated gambling in jurisdiction extends beyond direct gaming revenue, with more than $182 million disbursed to North Dakota communities during the 2023-25 biennium for charitable purposes. Funds support local schools, youth programs, veterans’ services, community projects, emergency response organizations, scholarships, and other public-spirited causes.
Employment figures in regulated gambling sector include Gaming Division staff (20 FTE positions) and employees of charitable gaming organizations, manufacturers, and distributors. Tribal gaming operators support jobs for more than 3,400 North Dakotans, though tribal gaming is regulated separately by tribal gaming commissions.
Historical growth trends in licensing and market expansion show dramatic increase in electronic pull-tab devices, with adjusted gross proceeds from e-tabs increasing from zero in 2018 to $213 million in 2024, representing nearly 500% increase. In contrast, adjusted gross proceeds from other types of charitable gambling decreased by 31% between 2015 and 2024.
Market concentration analysis shows electronic pull-tab devices dominate the market, accounting for $2.31 billion of $2.52 billion in total gross proceeds (91.6%) for Fiscal Year 2025. Twenty-one games generated $72.15 million, pull-tab dispensing devices $56.16 million, and bingo $24.05 million.
Emerging trends in license applications and product offerings include transition to online licensing and tax filing systems, QR code option for laws and rules access, and expanded training programs for organizations and boards of directors. The online licensing portal enables organizations to update details, employees, sites, and authorized game types throughout the year.
Public Transparency, Information Access, and Stakeholder Communication
Public license registry functionality and search capabilities are provided through the online licensing portal, which allows organizations to view current and past license applications in one place for easy reference. The Gaming Division maintains records of all licensed organizations and may provide information upon request.
Online database accessibility and user interface include the Gaming Division website with comprehensive resource library containing forms, laws, rules, newsletters, guidance documents, and FAQs. The website provides links to Games of Chance Century Code (Chapter 53-06.1) and Gaming Administrative Rules (Article 99-01.3) through the Legislative Council’s website.
Effective July 1, 2026, organizations may post a QR code to access gaming-related laws and administrative rules in lieu of having a physical copy on site, improving accessibility and reducing compliance burden.
Public meeting schedules and notice requirements include ND State Gaming Commission public hearings on proposed administrative rules. The February 18, 2026 public hearing on proposed rules for Article 99-01.3 was held at 1:00 pm at the North Dakota State Capitol, Brynhild Haugland Room, with oral and written comments accepted until March 7, 2026.
Meeting minutes and decision records availability includes quarterly newsletters (Gaming Insights) published by the Gaming Division, providing updates on regulatory changes, enforcement actions, and compliance guidance. Preliminary fiscal year reports are published with detailed gaming revenue and expense data.
Enforcement action disclosure policies and public reporting include press releases and website postings on enforcement actions, with media contacts providing information. The March 2026 Beulah CVB enforcement action and July 2023 distributor enforcement action were publicly disclosed through official channels.
Annual report publication and content scope includes preliminary fiscal year reports detailing gross proceeds, prizes, adjusted gross proceeds, cash profits, gaming taxes, federal excise tax, allowable expenses, net proceeds, eligible use contributions, and total actual expenses. Fiscal Year 2025 preliminary report was published in September 2025.
Financial disclosure requirements and public access extend to quarterly tax return filing by organizations, with online tax filing becoming mandatory beginning with the quarter ending September 30, 2026. Organizations must file tax returns online, with paper returns no longer accepted.
Regulatory guidance document availability includes downloadable PDFs on charitable gaming organization license application preparation, online licensing program information, local permitting policy interpretation, veterans’ organization use of net proceeds, and independent audit requirements.
Industry bulletins and advisory notices distribution occurs through quarterly newsletters (Gaming Insights), email communications to licensed organizations, and website postings. The Gaming Division maintains regular communication with stakeholders on regulatory changes and compliance expectations.
Public comment periods for regulatory changes are provided through ND State Gaming Commission public hearings, with opportunities for oral and written comments during designated periods. The February 2026 public hearing accepted comments until March 7, 2026.
Stakeholder consultation mechanisms and feedback processes include direct engagement with organizations through training programs, compliance assistance, and responsive communication via email ([email protected]) and phone ((701) 328-4848). The Gaming Division emphasizes cooperation, transparency, and mutual trust in regulatory relationships.
Freedom of information request procedures follow North Dakota public records laws, with requests submitted to the Office of Attorney General. The office does not process, take action in response to, or keep anonymous complaints.
Media relations and press release practices include official press releases on enforcement actions, regulatory changes, and organizational announcements, with media contact Suzie Weigel (701.328.2210, [email protected]) providing information.
Educational resources for consumers and the public include website FAQs, forms, laws and rules, newsletters, and guidance documents. The Gaming Division provides training and communications support to help organizations understand and comply with regulatory requirements.
Responsible Gambling Oversight, Player Protection, and Social Impact
Mandatory responsible gambling program requirements for licensees include compliance with prize limits, game integrity standards, and player protection measures established by statute and administrative rule. Organizations must ensure fair play, accurate prize redemption, and proper handling of player disputes.
Self-exclusion program administration and effectiveness are not explicitly detailed in available materials, though the division investigates consumer complaints and ensures prompt resolution of player disputes. The North Dakota gambling prevalence survey indicates problem gambling research and data collection efforts.
Organizations must take immediate action when gaming device incidents occur, stopping play on affected devices, contacting distributors, and following reporting requirements to protect player interests and game integrity.
Problem gambling data collection and reporting requirements include the North Dakota Gambling Prevalence Survey, which analyzes charitable gambling participation and problem gambling prevalence. Data from the Gaming Division on adjusted gross proceeds by game type informs research on gambling behavior and social impact.
Underage gambling prevention measures and enforcement include background check requirements for all employees, with criminal history checks conducted by the Bureau of Criminal Investigation. Organizations must verify employee eligibility and maintain compliance with statutory age restrictions.
Advertising restrictions and consumer protection standards prohibit online gaming and raffles, with state law expressly forbidding licensed organizations from conducting online gaming or accepting credit cards as wagers. Organizations must accurately represent gaming activities and net proceeds disbursements.
Complaint resolution and player dispute adjudication include investigation of consumer complaints involving electronic pull-tab devices and other gaming activities. The Gaming Division emphasizes prompt resolution of player disputes at the site level, with organizations responsible for taking immediate action when incidents occur.
Player fund protection mechanisms and segregation requirements include independent audit requirements ensuring accurate accounting of gaming funds. Organizations must maintain segregated gaming accounts with proper internal controls, including dual signatures on checks and independent audit of daily activities.
Treatment program funding and support initiatives are supported by gaming tax revenue, with approximately $53 million in gaming taxes for the 2023-25 biennium funding regulation, oversight, and gambling disorder programs. The remainder of gaming tax revenue is deposited into the State’s General Fund.
Research and data analysis on problem gambling prevalence includes the North Dakota Gambling Prevalence Survey, which examines charitable gambling participation rates and problem gambling indicators. The survey analyzes adjusted gross proceeds by game type and demographic participation patterns.
Collaboration with public health agencies and treatment providers extends to gambling disorder programs funded by gaming tax revenue. The North Dakota Department of Health and Human Services conducts gambling prevalence research using Gaming Division data.
Social impact assessments and harm minimization strategies include enforcement of net proceeds requirements ensuring funds benefit educational, charitable, patriotic, fraternal, religious, or public-spirited purposes. Fiscal Year 2025 data shows $95.13 million in eligible use contributions to charitable purposes.
Consumer education initiatives and awareness campaigns include quarterly newsletters, training programs, and website resources helping organizations and players understand regulatory requirements and responsible gaming practices. The Gaming Division emphasizes meaningful progress through cooperation, transparency, and mutual trust.
International Relations, Regulatory Cooperation, and Industry Engagement
Membership in international regulatory associations is not explicitly documented in available materials, though the Gaming Division participates in gaming regulator forums and training programs. The division maintains professional relationships with other state gaming regulators through information sharing and coordination on compliance matters.
Bilateral regulatory cooperation agreements and information sharing include coordination with tribal gaming commissions under five tribal-state Indian casino gaming compacts. The Gaming Division conducts random inspections at the state’s five Indian casinos to ensure game integrity and compliance with wager limits and prize payout ratios.
The Gaming Division enforces five tribal-state Indian casino gaming compacts, conducting random inspections at tribal casinos and coordinating with tribal gaming commissions on compliance matters.
Mutual recognition arrangements with other jurisdictions are not explicitly documented, though the division coordinates with other state gaming regulators on compliance and enforcement matters. Information sharing on licensing and enforcement actions supports cross-jurisdictional regulatory cooperation.
Cross-border enforcement collaboration and joint investigations include coordination with out-of-state law enforcement on gaming-related criminal investigations. The Investigation Section identified an out-of-state suspect in a Fargo-area charity office theft, demonstrating cross-border investigative cooperation.
Participation in international gaming conferences and forums is not explicitly documented, though the division maintains professional development and training programs for staff. The Training/Communications Specialist supports statewide training and outreach efforts.
Technical assistance provided to or received from other regulators includes coordination with city and county auditors who issue local permits, requiring them to provide copies of issued permits for statewide compliance review. The Gaming Division provides guidance and training to local permitting authorities on charitable gaming laws and rules.
Best practice sharing and peer review programs include quarterly newsletters sharing compliance guidance, enforcement updates, and regulatory changes with licensed organizations. The Gaming Division emphasizes cooperation, transparency, and mutual trust in regulatory relationships.
Multi-jurisdictional licensing initiatives and reciprocity agreements are not explicitly documented, though the division processes licenses for organizations operating in multiple cities and counties within North Dakota. Organizations pay $175 per city or county where gaming sites are authorized.
Industry association engagement and dialogue include regular communication with charitable gaming organizations through training programs, newsletters, and direct engagement. The Gaming Division welcomes feedback from organizations and stakeholders on regulatory processes and compliance requirements.
Advisory roles in global gaming policy development are not explicitly documented, though the division contributes to state-level policy development through administrative rule-making and legislative engagement. The ND State Gaming Commission conducts public hearings on proposed rules, incorporating stakeholder input.
Contributions to international regulatory standards are not explicitly documented in available materials. The Gaming Division focuses primarily on state-level regulatory oversight and enforcement of North Dakota charitable gaming laws and tribal-state compacts.
📋 How to Contact and Engage with North Dakota Office of Attorney General Gaming Division – Complete Communication Guide
Effective communication with the North Dakota Office of Attorney General Gaming Division requires understanding the division’s organizational structure, communication channels, and response expectations. The Gaming Division maintains multiple contact methods including phone, email, online portal, and physical mail, with specific protocols for different types of inquiries.
According to Gambling databases analysis, the Gaming Division emphasizes responsive communication with stakeholders, providing guidance on licensing, compliance, enforcement, and regulatory matters. Understanding appropriate communication channels and professional engagement practices improves response times and outcomes for operators, organizations, and the public.
Initial Contact Methods and General Inquiries
General contact initiation begins with the Office of Attorney General’s main switchboard at (701) 328-2210, which routes calls to appropriate divisions including the Gaming Division. For direct Gaming Division inquiries, callers should use (701) 328-4848 or the toll-free number 1-800-326-9240 within North Dakota. Business hours align with standard state office hours, with voicemail protocols in place for after-hours calls. Response times typically range from 2-5 business days for general inquiries, though urgent compliance matters may receive expedited attention.
Email communication is the preferred method for many Gaming Division interactions, with [email protected] serving as the primary contact address for licensing, compliance, and general inquiries. Appropriate email format includes clear subject lines identifying the organization, inquiry type, and urgency level. Attachments should be in PDF format and include relevant documentation such as license applications, incident reports, or compliance questions. Response expectations for email inquiries range from 3-7 business days, with urgent matters potentially receiving faster responses.
Website resources provide comprehensive self-service options through https://attorneygeneral.nd.gov/licensing-and-gaming/gaming/. The online portal provides public registry access, form downloads, FAQ sections, resource libraries, and news updates including quarterly newsletters (Gaming Insights). Organizations should review website resources before contacting the division, as many questions are answered through available guidance documents, forms, and FAQs.
Physical mail may be sent to North Dakota Office of Attorney General Gaming Division, 600 East Boulevard Avenue, Dept. 125, Bismarck, ND 58505-0040, though email is the preferred method of delivery to avoid mail delays and ensure timely receipt. The division maintains physical office hours for in-person visits by appointment, with advance scheduling recommended.
Social media presence is not prominently featured in available materials, with the Gaming Division focusing on direct communication through phone, email, and website channels. Media inquiries should be directed to Suzie Weigel at (701) 328-2210 or [email protected].
Accessibility accommodations are available for individuals with disabilities, with the division providing special facilities or assistance relating to disabilities upon request. Individuals requiring accommodations for public hearings or in-person meetings should contact the Gaming Division at least 7 days prior to the event.
Licensing Inquiries and Application Support
Licensing inquiries should be directed to [email protected] with clear subject lines identifying the organization and inquiry type. Pre-application consultations are available for organizations seeking guidance on eligibility, documentation requirements, and application processes. Organizations should gather required documents before applying, including tax-exempt certificates, articles of incorporation, by-laws, board minutes, and background check documentation.
Application status checks may be conducted through the online licensing portal, which provides access to current and past license applications. Organizations may view application status, upload additional documentation, and update organizational details through the portal. For complex status inquiries, organizations may contact the Gaming Division by email or phone.
Document submission occurs through the online licensing portal, with all required documents uploaded in PDF format during application or renewal. The Gaming Division cannot enter information or upload documents for organizations, and documents sent by email cannot be processed instead of portal submission. Organizations must ensure all data is entered directly in the portal and all required documents are uploaded within the application.
Licensing department contacts include the Licensing Section (Beth Leintz, Joshua Kopp) for application processing and licensing matters. For specific licensing questions, organizations should email [email protected] with detailed inquiries. Meetings with licensing staff are available by appointment, with 1-2 weeks lead time recommended for scheduling.
Technical support for the online licensing portal is available through the Gaming Division, with training opportunities and step-by-step guidance provided prior to system launch. Organizations experiencing technical difficulties should contact [email protected] for assistance.
Compliance Questions and Public Engagement
Compliance questions and interpretation requests should be submitted in writing to [email protected], with written requests preferred for formal opinions. Response times for formal compliance opinions range from 2-4 weeks, depending on complexity and staff availability. Guidance documents are available on the website addressing common compliance topics including independent audit requirements, online tax filing, and incident reporting.
Advisory opinions and guidance documents are available through the website, with quarterly newsletters (Gaming Insights) providing updates on regulatory changes and compliance expectations. Organizations may request specific guidance on novel compliance situations by emailing [email protected] with detailed factual scenarios.
Compliance officer contacts include the Audit Section (Laura Gleich, Section Supervisor) for audit-related questions and the Tax Section (Patty Wondra, Section Supervisor) for tax filing inquiries. For specific compliance questions, organizations should email [email protected] identifying the compliance topic and organizational context.
Complaints and enforcement matters should be reported through the online portal’s incident reporting feature or by contacting the Investigation Section. Special Agent Rob Sanderson (701) 328-5546) and Investigator Jacob Marschner (701) 328-2313) handle investigative matters. Complaint filing procedures require detailed information including organization name, incident description, dates, amounts, and supporting documentation. Investigation timelines range from 30-90 days depending on complexity, with confidentiality protections for complainants.
Public meetings and hearings are conducted by the ND State Gaming Commission on proposed administrative rules, with meeting schedules and notice requirements published on the website. Public comment registration is required 24-48 hours in advance, with testimony procedures outlined in meeting notices. Meeting minutes and decision records are available through the Gaming Division.
Freedom of information requests follow North Dakota public records laws, with requests submitted to the Office of Attorney General. The office does not process anonymous complaints. Processing times follow statutory requirements of 15-30 days, with fee structures for extensive record requests.
Effective communication strategies emphasize clarity, professionalism, and appropriate channel selection. Organizations should review website resources before contacting the division, use email for non-urgent inquiries, and reserve phone calls for time-sensitive matters. Professional engagement importance includes maintaining accurate contact information, responding promptly to division inquiries, and documenting all communications.
Response expectations vary by inquiry type, with general inquiries receiving 2-5 business day responses, email inquiries 3-7 business days, formal compliance opinions 2-4 weeks, and complaint investigations 30-90 days. Urgent compliance matters may receive expedited attention when properly identified.
⚖️ How to Navigate North Dakota Office of Attorney General Gaming Division Licensing and Compliance Processes
Navigating the North Dakota Office of Attorney General Gaming Division’s licensing and compliance processes requires thorough preparation, understanding of regulatory requirements, and commitment to ongoing compliance. The division’s transition to online licensing and tax filing systems (launched April 2026) streamlines processes while maintaining rigorous compliance standards.
Process complexity reflects the constitutional and statutory framework governing charitable gaming in North Dakota, with detailed eligibility criteria, documentation requirements, and ongoing compliance obligations. Stakeholder types include charitable organizations, veterans’ groups, fraternal organizations, religious organizations, educational institutions, civic groups, manufacturers, and distributors.
Professional guidance recommendations include consulting legal counsel for complex organizational structures, engaging accountants for financial compliance, and utilizing Gaming Division resources for regulatory guidance. The division emphasizes cooperation, transparency, and mutual trust in regulatory relationships.
Pre-Application Research and Preparation
Research phase requires 2-4 weeks to assess jurisdiction eligibility, license types, eligibility criteria, market conditions, and regulatory climate. Organizations must determine if they qualify as bona fide nonprofit organizations under North Dakota law, with registration as a nonprofit with the North Dakota Secretary of State required for at least two years prior to application. Eligible organization types include veterans’, charitable, educational, religious, fraternal, civic, and service organizations.
Preliminary consultation with the Gaming Division includes pre-application meetings to discuss eligibility, information gathering, feasibility, and timeline expectations. Organizations should contact [email protected] to schedule pre-filing meetings 3-4 weeks in advance. Informal feedback on organizational eligibility and documentation requirements may be obtained through these consultations.
Documentation preparation requires 4-8 weeks to assemble corporate documents, financials, backgrounds, business plans, and technical specifications. Required documents include: tax-exempt certificate issued by the IRS; Federal Employer Identification Number (FEIN); date of nonprofit registration with North Dakota Secretary of State; type of eligible organization; charter document (if applicable); articles of incorporation; charitable organization statement of primary purpose; corporate certificate; organizational by-laws; board of director meeting minutes for the previous two years.
Personnel documentation includes gaming manager information (name, phone, email, date of birth, record check date, record check document), top official information, governing board member information, primary contact selection, independent auditor information, and employee list with background check documentation. Record checks must be completed through the North Dakota Bureau of Criminal Investigation within 21 days of employment and every 6 years after.
Site authorization documentation includes SFN 17996 Gaming Site Authorization Form (completed and signed) and SFN 9413 Rental Agreement Form (completed and signed) or deed/title if the organization owns the premises. Organizations must identify all cities and counties where gaming will be conducted, with licensing fees of $175 per city or county.
Additional questions organizations must address include: whether the organization has ever had gaming violations (with explanation and documentation if yes); whether the organization currently holds a local permit for games of chance (with explanation and documentation if yes); whether the organization owns or rents the premises where games of chance will be conducted. All documents must be saved electronically in PDF format for upload during application.
Application Submission and Review Management
Application submission occurs through the online licensing portal, with all data entered directly by the organization and all required documents uploaded within the application. Form completion requires accurate entry of organizational information, personnel details, site authorizations, and jurisdiction lists. Fee payment is processed through the online portal, with cash and check payments no longer accepted.
Filing procedures require organizations to submit applications during designated filing periods, with the application window for Fiscal Year 2027 opening April 1, 2026, and submissions due by June 1, 2026. Manufacturers and distributors access the system first during their designated application window, followed by charitable gaming organizations with a 90-day filing period.
Confirmation receipt is provided through the online portal, with organizations able to view current and past license applications in one place. Application processing takes 1-2 weeks for initial review, with applications processed in the order received.
Investigation phase includes background checks, financial review, technical evaluation, interviews, and site inspections, taking 8-24 weeks depending on license type. The Investigation Section conducts criminal history background checks of applicants, officers, and stockholders. The Audit Section may conduct field audits to verify organizational information and site authorization.
Board/commission review includes ND State Gaming Commission consideration for administrative rule matters, with licensing decisions made by the Gaming Division based on Investigation Section and Audit Section recommendations. Hearing attendance may be required for certain license types or enforcement matters, with presentation preparation, question responses, and public comment periods. Final decisions are made 2-8 weeks after investigation completion.
Approval notification is provided through the online portal, with licenses and site authorizations available immediately upon approval and printable at any time. Organizations may update organization details, employees, sites, and authorized game types throughout the year through the portal.
Post-License Compliance and Ongoing Operations
Post-approval compliance requires 4-12 weeks before operations begin, including initial reporting setup, system certifications, operational approvals, staff licensing, and launch preparations. Organizations must ensure all employees complete background checks within 21 days of employment. Independent audit procedures must be established with qualified auditors meeting N.D. Admin. Code § 99-01.3-03-10(7) requirements.
Ongoing compliance includes periodic reporting, renewal procedures, amendment filings, compliance audits, and regulatory communication on continuous basis with annual/quarterly schedules. Quarterly gaming tax returns must be filed online, with mandatory online filing beginning with the quarter ending September 30, 2026. Tax payments may not be made by cash or check, and all extension requests must be submitted online.
Renewal procedures occur annually, with organizations completing full applications during initial submission and subsequent renewals requiring only updates to changed information. Previously entered information automatically carries forward in the online system. Renewal applications must be submitted during the 90-day filing period preceding the new fiscal year beginning July 1.
Amendment filings include updates to organization details, employees, sites, and authorized game types, which may be submitted through the online portal at any time during the year. Site authorization changes require SFN 17996 Gaming Site Authorization Form and SFN 9413 Rental Agreement Form (or deed/title) uploaded through the portal.
Compliance audits include independent audit of closed games or daily activities pursuant to N.D. Admin. Code § 99-01.3-03-10(7), with auditors verifying number and value of unsold chances, gross proceeds, prizes, adjusted gross proceeds, and cash profit. Gaming Division auditors conduct over 75 comprehensive and in-office audits during each biennium.
Regulatory communication includes quarterly newsletters (Gaming Insights), email updates on regulatory changes, and responsive communication via [email protected]. Organizations should maintain current contact information in the portal and respond promptly to Gaming Division inquiries.
Incident reporting requires organizations to submit incident reports directly through the online portal, with no separate emails or forms required. Electronic pull-tab device incidents require immediate action: stop play on affected device, contact distributor right away, and follow reporting requirements including contacting the Attorney General’s office when required.
Professional preparation emphasizes thorough documentation gathering, accurate application completion, and understanding of ongoing compliance obligations. Timeline management requires advance planning for application windows, background checks, document assembly, and renewal deadlines. Ongoing compliance commitment includes quarterly tax filing, independent audits, employee background checks, and responsive communication with the Gaming Division.
Legal counsel importance extends to complex organizational structures, enforcement matters, and novel compliance questions. Organizations facing administrative complaints or enforcement actions should consult legal counsel experienced in North Dakota gaming law.
❓ Frequently Asked Questions
What is the North Dakota Office of Attorney General Gaming Division and what is its primary regulatory mission?
The North Dakota Office of Attorney General Gaming Division is the state’s primary regulatory authority for charitable gaming, exercising comprehensive oversight over games of chance conducted by eligible nonprofit organizations. The division regulates, enforces, and administers charitable gaming in North Dakota, performing audits and investigations of gaming organizations, reviewing gaming tax returns and administrative complaints, and providing training for charitable gaming organizations.
The primary mission is to ensure fairness, integrity, and compliance with state law while helping nonprofit organizations raise funds that directly benefit North Dakota communities. The division emphasizes regulation and licensing that adapts to change while maintaining high integrity standards, ensuring responsible gaming practices across North Dakota’s charitable gaming sector.
Which types of gambling activities does the North Dakota Office of Attorney General Gaming Division regulate and oversee?
The Gaming Division regulates charitable gaming including bingo, pull-tabs (jar bar, dispensing devices, electronic devices), raffles (including electronic 50/50 systems), electronic quick shot bingo, sports pools, paddlewheels (with and without tables), twenty-one, poker, calcuttas, prize boards, club specials, tip/seal/punch boards, and raffle boards. The division also enforces five tribal-state Indian casino gaming compacts, conducting random inspections at the state’s five Indian casinos.
State law prohibits online gaming, with even licensed organizations forbidden from conducting online gaming or hosting raffles online. Credit cards cannot be accepted as wagers for gambling, including payment for raffle tickets. The North Dakota Lottery operates as a separate division within the Office of Attorney General and is not regulated by the Gaming Division.
How can operators contact the North Dakota Office of Attorney General Gaming Division for licensing inquiries?
Operators may contact the Gaming Division by email at [email protected], which is the preferred method for licensing inquiries. Phone contact is available at (701) 328-4848 or toll-free 1-800-326-9240 within North Dakota. Physical mail may be sent to 600 East Boulevard Avenue, Dept. 125, Bismarck, ND 58505-0040, though email is preferred to avoid mail delays.
The online licensing portal provides access to licensing information, forms, and application submission. Pre-application consultations are available by contacting [email protected] to schedule meetings 3-4 weeks in advance.
What license types does the North Dakota Office of Attorney General Gaming Division issue to gambling operators?
The Gaming Division issues charitable gaming organization licenses to bona fide nonprofit organizations conducting games of chance. Manufacturer licenses are issued for manufacturers of paper pull-tab dispensing devices ($1,500 fee), pull-tabs/bingo cards/electronic quick shot bingo systems ($5,500 fee), electronic pull-tab systems or devices ($10,000 fee), and electronic raffle systems ($1,000 fee).
Distributor licenses are issued annually with $2,000 fees. Site authorizations are required for each gaming location, with licensing fees of $175 per city or county where gaming sites are authorized. Local permits are issued by city or county auditors with Gaming Division oversight.
Where is the North Dakota Office of Attorney General Gaming Division headquartered and what is its jurisdictional coverage?
The Gaming Division is headquartered at 600 East Boulevard Avenue, Dept. 125, Bismarck, ND 58505-0040. Jurisdictional coverage extends statewide across all 53 North Dakota counties, with licensing fees assessed per city or county where gaming sites are authorized.
The division maintains statewide oversight of charitable gaming activities, including those conducted under local permits issued by city or county auditors. Tribal casino gaming on Indian lands is regulated primarily by tribal gaming commissions, with the Attorney General enforcing compact provisions.
Who leads the North Dakota Office of Attorney General Gaming Division and what is its organizational structure?
The Office of Attorney General is led by Attorney General Drew H. Wrigley, an elected constitutional officer. The Gaming Division is led by Division Director Aaron Hummel, appointed in 2025. The division consists of 20 FTE positions organized into functional sections.
Organizational structure includes Audit Section (supervised by Laura Gleich with 10 auditors), Tax Section (supervised by Patty Wondra with 4 staff), Investigation Section (supervised by Rob Sanderson with 3 investigators), Licensing Section (Beth Leintz, Joshua Kopp), Training/Communications Specialist (Arin Casavant), and Administrative Assistant (Susan Brockel).
What are the main compliance requirements for operators licensed by the North Dakota Office of Attorney General Gaming Division?
Main compliance requirements include quarterly online tax return filing (mandatory beginning Q3 2026), independent audit of closed games or daily activities pursuant to N.D. Admin. Code § 99-01.3-03-10(7), and employee background checks through the North Dakota Bureau of Criminal Investigation within 21 days of employment and every 6 years thereafter.
Organizations must maintain accurate records of gaming fund receipt, control, and disbursement, with independent auditors verifying unsold chances, gross proceeds, prizes, adjusted gross proceeds, and cash profit. Incident reports must be submitted through the online portal, with electronic pull-tab device incidents requiring immediate action.
How does the North Dakota Office of Attorney General Gaming Division enforce gambling regulations and what penalties can it impose?
The Gaming Division enforces regulations through audits, investigations, administrative complaints, and civil actions. The Attorney General may bring civil action for collection of fees and taxes and to force compliance under NDCC § 53-06.1-15.2. The division completed over 75 comprehensive and in-office audits and investigated over 197 complaints during the 2023-25 biennium.
Penalties include monetary fines (recent examples: $50,000 to Beulah CVB, $2,500 to NumberWorks LLC, $2,500 to individual), license revocations (Beulah CVB March 2026), repayment of improperly expended net proceeds ($398,287 from Beulah CVB), site authorization suspensions (90-day suspension of Uncle Maddio’s Pizza), and prohibitions on participation in gaming activities.
What is the typical timeline for obtaining a license from the North Dakota Office of Attorney General Gaming Division?
Application windows open April 1 for Fiscal Year 2027, with submissions due by June 1 and new fiscal year beginning July 1. Applications are processed in the order received, with manufacturers and distributors accessing the system first during their designated window, followed by charitable gaming organizations with a 90-day filing period.
Investigation phase includes background checks, financial review, technical evaluation, interviews, and site inspections, taking 8-24 weeks depending on license type. Final decisions are made 2-8 weeks after investigation completion. Overall timeline from application to approval typically ranges 3-6 months.
Does the North Dakota Office of Attorney General Gaming Division maintain a public registry of licensed operators?
The online licensing portal provides access to current and past license applications for organizational reference. The Gaming Division maintains records of all licensed organizations and may provide information upon request. Public registry functionality allows organizations to view their license status and history through the portal.
Comprehensive public search capabilities are not explicitly detailed in available materials, though the division provides information on licensed organizations through direct inquiries. Quarterly newsletters and preliminary fiscal year reports provide aggregate data on licensed organizations.
What responsible gambling measures does the North Dakota Office of Attorney General Gaming Division require from licensees?
Responsible gambling measures include compliance with prize limits, game integrity standards, and player protection measures established by statute and administrative rule. Organizations must ensure fair play, accurate prize redemption, and proper handling of player disputes. Independent audit requirements ensure accurate accounting of gaming funds and prize distributions.
Organizations must take immediate action when gaming device incidents occur, stopping play on affected devices, contacting distributors, and following reporting requirements. Net proceeds must be devoted to educational, charitable, patriotic, fraternal, religious, or public-spirited purposes, with $95.13 million in eligible use contributions for Fiscal Year 2025.
How does the North Dakota Office of Attorney General Gaming Division handle consumer complaints and player disputes?
Consumer complaints are handled through the Investigation Section, which investigated over 197 complaints during the 2023-25 biennium. Complaints may be filed through the online portal’s incident reporting feature or by contacting the Investigation Section directly. Special Agent Rob Sanderson (701) 328-5546) and Investigator Jacob Marschner (701) 328-2313) handle investigative matters.
Player disputes involving electronic pull-tab devices require immediate action at the site level, with organizations responsible for stopping play, contacting distributors, and following reporting requirements. The Gaming Division emphasizes prompt resolution of player disputes, with investigation timelines ranging 30-90 days depending on complexity.
What are the inspection and audit requirements under North Dakota Office of Attorney General Gaming Division oversight?
Inspection requirements include the Attorney General’s statutory authority to inspect all sites where gaming is conducted or where gaming equipment is manufactured or distributed. The Gaming Division conducts random inspections at the state’s five Indian casinos to ensure game integrity and compliance with wager limits and prize payout ratios.
Audit requirements include independent audit of closed games or daily activities pursuant to N.D. Admin. Code § 99-01.3-03-10(7), with auditors verifying unsold chances, gross proceeds, prizes, adjusted gross proceeds, and cash profit. The Gaming Division completed over 75 comprehensive and in-office audits during the 2023-25 biennium.
Can North Dakota Office of Attorney General Gaming Division licenses be recognized in other jurisdictions?
North Dakota charitable gaming licenses are valid only within North Dakota jurisdiction and are not recognized in other jurisdictions. Organizations operating in multiple states must obtain separate licenses in each jurisdiction where gaming activities occur.
Multi-jurisdictional licensing initiatives and reciprocity agreements with other states are not explicitly documented in available materials. Organizations operating in multiple cities and counties within North Dakota pay $175 licensing fee per city or county where gaming sites are authorized.
What is the history and establishment background of the North Dakota Office of Attorney General Gaming Division?
The Gaming Division operates under constitutional and statutory authority established through Article XI, Section 25 of the North Dakota Constitution, which prohibits gambling unless expressly authorized while permitting bona fide nonprofit organizations to conduct games of chance when net proceeds benefit public-spirited purposes. Chapter 53-06.1 of the North Dakota Century Code (Games of Chance) constitutes the primary statutory authority, with substantive amendments effective August 1, 2025.
The organizational structure is defined in N.D. Admin. Code § 10-01-01-01, establishing the Gaming Division as one of 13 divisions within the Office of Attorney General. Historical development includes 1987 legislation (S.L. 1987, Ch. 627) expanding the Attorney General’s responsibilities to include compliance enforcement with tribal-state Indian casino gaming compacts. Major regulatory reforms include the 2026 transition to comprehensive online licensing and tax filing systems.
📞 Sources
Official Regulatory Sources
- North Dakota Office of Attorney General Gaming Division – Official Website
- Gaming Licensing Information and Online Portal
- Gaming Laws, Rules, and Publications
- Fiscal Year 2025 Preliminary Report of Activities
- Gaming Insights Quarterly Newsletter (January 2026)
- Charitable Gaming License Application Preparation Guide
- Gaming Complaint Information and Enforcement Actions
Government and Legislative Resources
- North Dakota Century Code Chapter 53-06.1 (Games of Chance)
- Office of Attorney General 2027-29 Base-Level Budget
- North Dakota Executive Budget 2025-27
- Legislative Committee Memorandum on Gaming Ownership Restrictions
- Analysis of Major Special Funds 2023-25
Industry Analysis and Legal Commentary
- American Gaming Association – North Dakota Economic Impact Report
- North Dakota Gambling Prevalence Survey Final Report
- Gambling and Problem Gambling in North Dakota: 2024
- Tribal Gaming in North Dakota and Wisconsin – Legislative Analysis
- Harbor Compliance – North Dakota Charitable Gaming License Guide
International Regulatory Resources
- Tribal-State Gaming Compact Documents
- Bureau of Indian Affairs – Tribal Gaming Compact Information
- North Dakota Administrative Code – Office Organization
- FindLaw – North Dakota Century Code Annotated
- North Dakota State Historical Society – Attorney General Archives
🏛️Gambling Databases Rating: North Dakota Office of Attorney General Gaming Division
| Evaluation Dimension | Score | Rating |
|---|---|---|
| Regulatory Effectiveness Score | 6.8/10 | 🟡Good 5-7 |
| Stakeholder Accessibility Score | 7.2/10 | 🟡Good 5-7 |
| Overall GDR Rating | 7.0/10 | Functional state-level charitable gaming regulator with solid enforcement but limited jurisdictional scope and no commercial/online gambling oversight |
| Regulatory Reputation | ⭐⭐⭐ Developing Tier – Respected within U.S. state regulatory community for charitable gaming oversight, but limited international recognition due to narrow jurisdictional focus on nonprofit gaming only | |
This rating is calculated using the Gambling Databases Rating (GDR) methodology, which provides transparent criteria for evaluating gambling regulators for the iGaming industry. Click the link to learn how we calculate Regulatory Effectiveness Score, Stakeholder Accessibility Score, and Regulatory Reputation ratings.
⚠️CRITICAL CONCERNS & OPERATIONAL REALITIES
READ THIS BEFORE ENGAGING WITH THIS REGULATOR:
- Limited jurisdictional scope: Regulates only charitable gaming (nonprofit organizations); no commercial casino, sports betting, or online gambling licensing authority – North Dakota Constitution prohibits commercial gambling
- Online gaming prohibition: State law expressly forbids even licensed organizations from conducting online gaming or hosting raffles online; credit cards cannot be accepted as wagers
- Modest staffing levels: Only 20 FTE positions (13 auditors, 2 investigators) for 300+ licensed organizations at nearly 1,000 locations statewide – stretched but managing
- No public license search database: Online portal provides access to current and past license applications for organizational reference only; no comprehensive public searchable registry
- Limited player protection framework: No self-exclusion program documented; dispute resolution emphasizes site-level resolution rather than formal regulatory adjudication
- Minimal international engagement: No documented membership in IAGR/GREF; limited to tribal-state compact enforcement and domestic coordination
📊Regulatory Effectiveness Score Breakdown
| Criterion | Weight | Score | Justification (INCLUDING ALL DEDUCTIONS) |
|---|---|---|---|
| Organizational Capacity & Resources | 20% | 1.4/2.0 | Moderate resources (+1.5). 20 FTE positions for 300+ organizations at 1,000 locations is stretched (-0.3). Recent modernization with online licensing system (+0.2). No evidence of chronic budget shortfalls – funded by $53M gaming tax revenue biennium. Limited specialized gambling expertise beyond charitable gaming (-0.3). Final: 1.4/2.0 |
| Licensing & Application Management | 25% | 2.0/2.5 | Clear processes with online portal (+2.0). 90-day filing period with predictable timeline. Mandatory online system launched April 2026 improves efficiency. Processing times 3-6 months total (reasonable). No evidence of arbitrary rejections or favoritism. Unclear approval/rejection criteria not explicitly published (-0.3). Minor communication gaps during application (-0.2). Final: 2.0/2.5 |
| Compliance Monitoring & Enforcement | 30% | 2.3/3.0 | Proactive monitoring with 75+ audits per biennium (+2.3). Consistent enforcement with published actions (Beulah CVB revocation March 2026, distributor enforcement July 2023). Public disclosure of enforcement actions through press releases. Penalties proportionate ($50K fine, $398K repayment for serious violations). No evidence of selective enforcement. Inspection frequency adequate for charitable gaming scope. Limited investigation capacity with only 2 investigators (-0.3). No public database of all enforcement actions (-0.4). Final: 2.3/3.0 |
| Player Protection & Responsible Gambling | 15% | 0.8/1.5 | Basic protection through audit requirements and incident reporting (+0.8). No functioning formal player dispute resolution mechanism – emphasizes site-level resolution (-0.5). No documented self-exclusion program (-0.3). Inadequate responsible gambling requirements beyond prize limits and game integrity (-0.3). No player fund segregation enforcement explicitly documented (-0.4). Problem gambling research conducted but limited regulatory requirements (-0.2). Final: 0.8/1.5 |
| Regulatory Independence & Integrity | 10% | 0.9/1.0 | Fully independent with no corruption concerns (+0.8). Attorney General is elected constitutional officer providing political accountability. No evidence of political interference in staffing/budget. No documented corruption or bribery cases. Gaming tax revenue funds operations reducing industry capture risk (+0.1). Minor political considerations inherent in elected AG structure (-0.1). Final: 0.9/1.0 |
🤝Stakeholder Accessibility Score Breakdown
| Criterion | Weight | Score | Justification (INCLUDING ALL DEDUCTIONS) |
|---|---|---|---|
| Transparency & Information Access | 30% | 2.3/3.0 | Generally transparent with comprehensive website (+2.3). Quarterly newsletters (Gaming Insights) published. Preliminary fiscal year reports with detailed statistics. Public hearing notices for rule changes. Enforcement actions disclosed through press releases. No comprehensive public license search database (-0.5). Regulations only in English (no issue). Website functional and updated. Budget information disclosed in legislative documents. No FOIA denial evidence. Final: 2.3/3.0 |
| Communication & Responsiveness | 25% | 2.0/2.5 | Multiple channels: phone (701-328-4848), email ([email protected]), online portal (+2.0). Response times 2-5 business days for general inquiries, 3-7 days for email (reasonable). Dedicated licensing inquiry contact available. Website has clear contact information. Published guidance documents and FAQs available. No multilingual support beyond English (-0.3). Staff generally helpful based on training programs. Pre-licensing consultation available by appointment. Final: 2.0/2.5 |
| Procedural Fairness & Due Process | 20% | 1.7/2.0 | Clear procedures with administrative hearing process under NDCC chapter 28-32 (+1.5). Notice and comment periods for rule changes. Appeal rights for denied applications and enforcement actions. Opportunity to respond before penalties (Beulah CVB case). Advance notice for enforcement actions. Decisions include stated reasoning in enforcement actions. Minor gaps in expedited procedures (-0.3). No evidence of impartial hearing concerns. Final: 1.7/2.0 |
| Industry Engagement & Support | 15% | 1.2/1.5 | Regular dialogue through quarterly newsletters (+1.2). Training programs for organizations and gaming personnel. Compliance assistance through guidance documents. ND State Gaming Commission provides consultation mechanism. Pre-licensing consultation available. Generally cooperative relationship with charitable gaming organizations. No formal industry advisory committee documented (-0.3). Some operators may perceive enforcement-focused approach. Final: 1.2/1.5 |
| International Cooperation | 10% | 0.5/1.0 | Minimal international engagement (+0.5). No documented IAGR/GREF membership (-0.3). Tribal-state compact enforcement provides limited cross-border cooperation. Coordination with other state gaming regulators on compliance matters. No mutual assistance agreements with major international jurisdictions (-0.3). Limited international recognition due to narrow charitable gaming focus (-0.2). No evidence of refusing cross-border cooperation. Final: 0.5/1.0 |
🌍Regulatory Reputation Analysis
Industry Standing: ⭐⭐⭐
Reputation Tier: Developing Tier – Functional and respected within U.S. state regulatory community for charitable gaming oversight, but limited international recognition due to narrow jurisdictional scope
Operator Perception: Viewed as professional and predictable for charitable gaming operators; fair enforcement with clear procedures; limited appeal for commercial/online operators due to jurisdictional restrictions
International Standing: Neutral to positive among U.S. state regulators; limited visibility internationally due to focus on nonprofit charitable gaming rather than commercial/online gambling
Consumer Advocacy View: Adequate for charitable gaming consumer protection; concerns about limited formal dispute resolution mechanisms and lack of self-exclusion program
Payment Provider Acceptance: Not applicable for online gambling (prohibited); charitable gaming payment processing straightforward with no documented issues
B2B Platform Perception: Limited relevance – no online gambling platforms; gaming equipment manufacturers view as legitimate regulator for charitable gaming equipment
Regulator-Specific Reputation Factors:
- Enforcement Track Record: Consistent and fair enforcement within charitable gaming scope; documented actions (Beulah CVB revocation, distributor enforcement) demonstrate willingness to act
- Documented Controversies: No corruption scandals; enforcement actions viewed as legitimate and proportionate
- Media Coverage: Neutral to positive coverage in state media; enforcement actions reported factually without controversy
- Peer Regulator View: Respected among U.S. state charitable gaming regulators; limited interaction with international commercial gambling regulators
- Professional Development: Recent modernization with online licensing system (2026); quarterly training programs; investment in technology infrastructure
- Leadership Quality: Professional leadership under Division Director Aaron Hummel (appointed 2025); Attorney General Drew Wrigley provides elected accountability
Known Issues or Concerns:
- Limited jurisdictional scope – only charitable gaming, no commercial/online gambling
- No formal self-exclusion program for problem gambling
- Limited public license registry functionality
- Minimal international regulatory cooperation
- Small investigation staff (2 investigators) for statewide oversight
🔍Key Highlights
✅Strengths
- Clear statutory framework under NDCC Chapter 53-06.1 and N.D. Admin. Code Article 99-01.3
- Consistent enforcement with published actions and proportionate penalties
- Modern online licensing system launched April 2026 improving efficiency
- Transparent funding through gaming tax revenue ($53M biennium) reducing corruption risk
- Comprehensive website with guidance documents, forms, and quarterly newsletters
- Responsive communication with 2-5 business day response times
- Strong procedural fairness with administrative hearing rights under NDCC chapter 28-32
- $95.13M in eligible use contributions to charitable purposes (FY 2025) demonstrating mission effectiveness
⚠️Weaknesses
- Limited to charitable gaming only – no commercial casino, sports betting, or online gambling authority
- Only 20 FTE positions (13 auditors, 2 investigators) for 300+ organizations at 1,000 locations
- No comprehensive public searchable license database
- No formal self-exclusion program documented
- Limited player dispute resolution – emphasizes site-level rather than regulatory adjudication
- No documented IAGR/GREF membership or international cooperation
- Online gaming expressly prohibited by state law
- Regulations only in English (not material issue for North Dakota)
🚨CRITICAL ISSUES
- Integrity Concerns: None documented – no corruption allegations, conflicts of interest, or regulatory capture evidence
- Capacity Problems: Modest staffing (20 FTE) stretched across 300+ organizations at 1,000 locations; only 2 investigators for statewide enforcement
- Transparency Failures: No comprehensive public license search database; enforcement actions disclosed through press releases but not centralized database
- Enforcement Dysfunction: None documented – enforcement appears consistent and proportionate within charitable gaming scope
- Player Protection Gaps: No self-exclusion program; limited formal dispute resolution; emphasizes site-level resolution over regulatory adjudication
- Communication Breakdown: None significant – generally responsive with multiple contact channels and reasonable response times
⚖️Regulatory Environment Assessment
Working with This Regulator:
For Operators: Charitable gaming operators can expect professional, predictable oversight with clear procedures and fair enforcement. Licensing process modernized with online system (2026). Compliance burden moderate with quarterly tax filing and independent audit requirements. Not applicable for commercial/online gambling operators – jurisdiction prohibits these activities.
For Players: Adequate protection for charitable gaming participants through audit requirements and incident reporting. Limited formal dispute resolution – complaints handled at site level with regulatory investigation for serious matters. No self-exclusion program. Fund protection through independent audit requirements but no explicit segregation mandate.
For Payment Providers: Low risk for charitable gaming payment processing. No online gambling means no payment processing complexities. Traditional payment methods (cash, check) dominate charitable gaming.
For Investors: Low regulatory risk for charitable gaming operators under this oversight. Stable regulatory environment with consistent enforcement. Limited growth potential due to jurisdictional restrictions on commercial/online gambling. North Dakota’s small market (740K population) limits scale.
Operational Predictability:
Licensing Process: Clear and predictable with online portal, 90-day filing period, and 3-6 month total processing time. Published requirements and documentation checklists.
Ongoing Oversight: Professional and consistent with quarterly tax filing, independent audits, and periodic Gaming Division audits. Cooperative relationship with charitable organizations.
Enforcement Actions: Fair and proportionate with published reasoning. Penalties calibrated to violation severity (e.g., $50K fine + $398K repayment for serious Beulah CVB violations). Due process protections through administrative hearings.
Stakeholder Communication: Responsive and helpful with 2-5 business day response times. Multiple contact channels. Quarterly newsletters provide regulatory updates. Training programs available.
Risk Factors:
- Regulatory Capture Risk: Low – funded by gaming tax revenue going to General Fund, not direct industry control. Elected Attorney General provides political accountability.
- Political Interference Risk: Low to moderate – elected Attorney General structure creates inherent political considerations, but no evidence of interference in licensing/enforcement decisions.
- Corruption Risk: Low – no documented corruption allegations. Transparent funding and enforcement actions. Professional staff with low turnover.
- Competence Risk: Low – professional staff with appropriate expertise for charitable gaming oversight. Recent modernization demonstrates competence.
- Stability Risk: Low – stable leadership with Division Director Aaron Hummel (2025). Elected Attorney General provides continuity. No frequent policy shifts.
📋Final Verdict
North Dakota Office of Attorney General Gaming Division receives a Regulatory Effectiveness Score of 6.8/10 and a Stakeholder Accessibility Score of 7.2/10, resulting in an Overall GDR Rating of 7.0/10. The regulator has a Regulatory Reputation rating of ⭐⭐⭐.
HONEST ASSESSMENT: This is a competent, professional state-level regulator effectively overseeing North Dakota’s charitable gaming sector with clear procedures, consistent enforcement, and transparent operations. However, its jurisdictional scope is strictly limited to nonprofit charitable gaming – commercial casinos, sports betting, and online gambling are prohibited by state constitution and law. For charitable gaming operators, this provides predictable, fair oversight with modern systems. For commercial/online gambling operators, this jurisdiction is simply not available. Player protection is adequate but not comprehensive, lacking self-exclusion programs and formal dispute resolution mechanisms.
✅Suitable For /❌Avoid If
✅OPERATORS SHOULD CONSIDER IF:
- Nonprofit charitable organization seeking to conduct bingo, pull-tabs, raffles, or other authorized games of chance in North Dakota
- Veterans, fraternal, religious, or civic organizations wanting to raise funds through charitable gaming
- Gaming equipment manufacturers targeting charitable gaming market in North Dakota
- Organizations value transparent, predictable regulatory oversight with fair enforcement
- Operators seeking modern online licensing system with responsive communication
❌OPERATORS SHOULD AVOID IF:
- Commercial casino operator – North Dakota Constitution prohibits commercial gambling
- Online gambling/sports betting operator – state law expressly prohibits online gaming
- Seeking large-scale commercial gambling market – North Dakota has 740K population with only charitable gaming
- Need comprehensive player protection framework including self-exclusion programs
- Require international regulatory recognition for online gambling operations
- Concerned about limited public license registry functionality
👥PLAYER CONSIDERATIONS:
- Choose operators under this regulator if: Participating in charitable gaming (bingo, pull-tabs, raffles) at licensed nonprofit organizations; value games with independent audit requirements and regulatory oversight; comfortable with site-level dispute resolution
- Avoid operators under this regulator if: Seeking online gambling options (prohibited in North Dakota); require formal self-exclusion programs for problem gambling; need comprehensive regulatory dispute resolution mechanisms
⚖️BOTTOM LINE:
Competent state-level charitable gaming regulator with professional oversight, fair enforcement, and modern systems – but jurisdictional scope limited exclusively to nonprofit charitable gaming with no commercial or online gambling permitted. Ideal for legitimate charitable organizations conducting gaming fundraisers in North Dakota; irrelevant for commercial/online gambling operators.








